Privacy Policy

Privacy Policy

Last Modified: May 25, 2018

Introduction

STRATAFOLIO, INC. respects your privacy and we are fully committed to protecting the privacy of our customers and visitors. This statement details the steps we take to protect the personal information provided on our website. The Policy describes the types of personal information that we collect and the purposes for which we use such information. By accessing our website, users are consenting to the information collection and use practices described in this privacy statement. STRATAFOLIO may amend this Privacy Policy by posting an updated Privacy Policy without advance notice to you. Such revisions shall be effective immediately upon posting. 

1. Information the Services Obtain and Use

Non-personal Data. Non-personal Data means any information that does not directly identify you, including “automatically collected data,” “aggregated” or “anonymized” information that STRATAFOLIO collects to inform it how others use the Services. Such Non-personal Data includes, but is not limited to, (i) device properties, including, but not limited to, type, IP address, Media Access Control (“MAC”) address and unique device identifier or other persistent or non-persistent device identifier (“Device ID”); (ii) device software platform, operating system, type of Internet browser, and firmware; (iii) mobile phone carrier; (iv) web browsing patterns, including websites visited; (v) geographical data such as zip code, area code, and other non-precise location information; (vi) the way in which you use the Services, including frequency and duration of usage; and (vii) other Non-personal Data as reasonably required by STRATAFOLIO to enhance the Services. In order to collect such Non-personal Data, STRATAFOLIO may use tools, such as cookies, described below, or third party analytical software to automatically collect and use such Non-personal Data, including products by Google, Inc., such as Google Analytics, and HubSpot.

Cookies and Similar Technologies. Cookies are small files created by your web browser to assign a unique id to your computer. STRATAFOLIO uses cookies, as well as other monitoring technology such as tags, web beacons, local shared objects, files, tools, and programs to gather Non-personal Data for use in our records, to store your preferences, and improve our advertising through our use of Google services and HubSpot. You can disable cookies in your web browser at any time, but some functionality of our Site may be impaired if you disable cookies. 

Our site may also contain electronic images known as tracking pixels which allows us to count user visits. We may also include tracking pixels in e-mail messages or newsletters to determine if messages have been accessed.

Personally Identifiable Information (“PII”). PII means personally identifiable information that specifically identifies you as an individual. STRATAFOLIO obtains some of your PII such as your name and email address. You will also be asked to provide a username and password. Other ways in which STRATAFOLIO may obtain your PII include, accessing Services with a third party ID, such as social networking sites, subscribing to STRATAFOLIO updates, purchasing products or services through  STRATAFOLIO’s online store or respond to any offers, requesting technical support, and when PII is otherwise required for use of the Services. Your decision to give STRATAFOLIO, and their product Stratafolio, your PII is optional, but some or all the Services may not be available until you register.

STRATAFOLIO may use your PII to contact you from time to time to provide you with important information, commercial content, special offers, updated information, required notices, and marketing promotions. STRATAFOLIO may also share encrypted versions of information you have provided in order to enable our partners to append other available information about you for analysis or advertising-related use.

STRATAFOLIO may use PII and Non-personal Data, both individually and combined together, for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving), customizing STRATAFOLIO’s communications and to further develop the Services. STRATAFOLIO may combine Non-personal Data with personal data.

By using the Services, you are consenting to STRATAFOLIO’s Processing (as defined below) of your PII and any Non-personal Data as described in this Privacy Policy. Processing means the use of PII and any Non-personal Data provided by you or gathered using cookies on a computer/mobile device in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. By using the Services and providing information to us, you consent to such transfer to, and processing in, the U.S.

2. Disclosure of Non-personal Data and personally identifiable information

 STRATAFOLIO may share Non-personal Data and your PII with third parties in the following ways:

  • As required by law, such as to comply with a subpoena or similar legal process;
  • When STRATAFOLIO believes in good faith that disclosure is necessary to protect its rights, protect your safety or the safety of others, investigate fraud, or respond to a government request;
  • With trusted service providers who work on behalf of STRATAFOLIO, and do not have an independent use of the information being disclosed, and have agreed to adhere to the rules set forth in this Privacy Policy; and
  • If STRATAFOLIO is involved in a merger, acquisition, or sale of all or a portion of its assets, in which case you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of PII, as well as any choices you may have regarding this information.
  • To advertisers and third-party advertising networks and analytics companies as described above.

 STRATAFOLIO may work with third parties to serve to advertise. These third parties may use Non-personal Data to determine how users interact with advertising provided in the Services. They gather this information using cookies and other technology.   This Privacy Policy does not cover collection methods or the use of such information collected by third parties. Advertising enables STRATAFOLIO to keep the cost of the Services low.

STRATAFOLIO may also use and disclose to third parties any Non-personal Data that STRATAFOLIO collects to manage and provide the Services, as well as to further develop the Services. You hereby acknowledged and agree that any third party analytics companies or advertising companies utilized by STRATAFOLIO may combine the information collected with other information they have independently collected from other services or products relating to your activities. The combination of  STRATAFOLIO’s Non-personal Data with their data may turn otherwise non-personal data into personally identifiable data. These companies collect and use information under their own privacy policies.

STRATAFOLIO shares PII only with the owner’s informed consent. With your consent, from time-to-time, STRATAFOLIO may provide its business partners with contact details for direct marketing purposes of relevant services, products, and programs. If you no longer wish your information to be shared, please let us know.

Deletion (Opt-Out). In order to delete the PII you submitted, notify us at [email protected] that you wish to delete your PII or any part thereof contained at our databases. STRATAFOLIO will respond to your request within a reasonable time, and use commercially reasonable efforts to delete your PII; however, it may be impractical to remove all of your PII without some residual information being retained by STRATAFOLIO.   Please note that some or all the PII may be required in order for you to properly use the Services. STRATAFOLIO may also be required to retain some or all of your PII by law.

Modification. You can modify or update your PII in your account settings. If you need help, please contact us at [email protected]. Please note that deletion of your PII from our database will not prevent STRATAFOLIO from using gathered anonymous information.

3. California’s “do not track” law

Do Not Track (DNT) is a privacy preference that users can set in their web browsers. STRATAFOLIO’s Services do not currently respond to Do Not Track (DNT) signals.

4. Children’s Privacy

STRATAFOLIO does not knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]. STRATAFOLIO will delete such information from our files within a reasonable time.

5. Security

STRATAFOLIO is concerned about safeguarding the confidentiality of your PII. We provide commercially reasonable physical, electronic, and procedural safeguards to protect the information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve the Services. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches, and there is the possibility that despite STRATAFOLIO’s reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you hereby acknowledge and assume this risk.

6. Disputes and Legal Proceedings

STRATAFOLIO regularly reviews its compliance with this Privacy Policy. If STRATAFOLIO receives a formal written complaint from you, STRATAFOLIO will attempt to contact you directly to address any of your concerns. STRATAFOLIO will cooperate with the appropriate governmental authorities to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and STRATAFOLIO. The Services are governed by the laws of the State of Iowa, without regard to its conflict of laws provisions. Any dispute, controversy or claim arising out of or relating to this Privacy Policy or the breach, termination or validity thereof shall be finally settled at STRATAFOLIO’s discretion (i) in the Iowa District Court for Linn County, or the United States District Court for the Northern District of Iowa; or (ii) in binding arbitration in the city of Cedar Rapids, Iowa by a panel of three arbitrators chosen, and an arbitration proceeding conducted in accordance with the rules then applying of the American Arbitration Association. The prevailing party in any such action or arbitration shall be entitled to an award of its reasonable attorney’s fees and other costs incurred with respect to such arbitration. The parties further agree that judgment on the award rendered by the arbitrators may be entered in any court having jurisdiction thereof. YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST STRATAFOLIO ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

7. Compliance with the General Data Protection Regulation (GDPR)

STRATAFOLIO’s procedures meet the general spirit as outlined in GDPR. Should there be a security breach of our customer’s private data, the required reporting protocols will be followed.

8. Contact us

If you have any questions regarding privacy while using the Services, or have questions about our practices, please contact us via email at [email protected]. You can also reach us by postal mail at:

STRATAFOLIO, Inc.

415 12th Ave SE

Cedar Rapids, IA 52401

Pursuant to Section 1798.83 of the California Civil Code, residents of California can obtain certain information about the types of personal information that companies with whom they have an established business relationship have shared with third parties for direct marketing purposes during the preceding calendar year. The law provides that companies must inform consumers about the categories of personal information that have been shared with third parties, the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. To request a copy of the information disclosure provided by STRATAFOLIO pursuant to Section 1798.83 of the California Civil Code, please contact us via the email or address stated above. Please allow 30 days for a response.